What The Code Covers

Principles, values and rules of behavior that guide decisions, procedures and actions

A broad range of topics, from avoiding conflicts of interest to fighting corruption to preventing discrimination and harassment

The process and protocol for report violations

What Is Not Covered

While our Code Of Conduct is fairly comprehensive, there are some exceptions:

Every possible ethical dilemma you may encounter

A single answer to every question the Code raises, especially in the case of complex or ambiguous issues

Possible situations that may require further investigation or consultation with available company resources

Our Commitment

Our company is committed to maintaining and distributing the Code Of Conduct to our employees, third parties with who we do business, and the community. All employees are responsible for reading and meeting the requirements of the Code.

Your Responsibilities

We encourage every member of our team to learn and embrace our Code Of Conduct.

Take action and “Walk the Talk”

Know the Code

Be attentive for potential threats to our company’s integrity, both blatant and subtle

Keep the Code current and useful by bringing up areas that need to be addressed

Situation And Solutions

To help you better understand how our Code Of Conduct might applies to how we all do our jobs, we’ve applied it to the three brief work scenarios below.

Situation #1

Potential Conflict Of Interest

I work in the IT department. One of our customers asked if I could work with him on weekends to help set up a new accounting system. Since this project is different from the work I do for the customer through our company, may I take on the contract work?

Ask Yourself

What feels wrong about this situation or action?

Is this situation against company policy or the law?

How could my decision affect my reputation and that of the company?

Solution

NO. This situation represents a conflict of interest. In order to avoid the perception that you might offer preferential treatment to this customer, you must decline the arrangement. Refer the customer to the conflicts of interest section of our Code.

Situation #2

CodeDiffers From Standard Procedure

I discovered a section in our Code that conflicts with how we actually operate in the field. Should I report this to anyone, though everyone knows the standard procedure?

Ask Yourself

What feels wrong about this situation or action?

Is this situation against company policy or the law?

How could my decision affect my reputation and that of the company?

Solution

YES. Our Code of Conduct is a dynamic document. Contact the compliance department with your suggested changes. If they are approved, the Code will be updated to reflect current practice.

Situation #3

An Issue Not Directly Addressed By Code

Recently I encountered an issue that, as far as I can tell, is not addressed in our Code. In deciding how to handle it, should I just follow my instincts?

Ask Yourself

What feels wrong about this situation or action?

Is this situation against company policy or the law?

How could my decision affect my reputation and that of the company?

Solution

MAYBE. It depends on the circumstances and how quickly you need to take action. Feel free to sort out the issue with your manager. As a follow-up, he or she may advise you to contact the compliance department to determine whether the issue should be added to our Code.